Modern Slavery and Human Trafficking Statement
This statement is made on behalf Catalina Holdings Bermuda Limited (“CHBL”) and all of its subsidiaries, including, but not limited to, the companies based or operating in the United Kingdom (the “Catalina Group”). This statement sets out the steps we have taken to minimise the risk of modern slavery in our business and supply chains around the world and constitutes our Modern Slavery and Human Trafficking statement for the financial year ended 31 December 2021 as required under the provisions of the Modern Slavery Act 2015. It is reviewed annually.
Our organisational structure and operations
CHBL, which has its headquarters in Bermuda, is the parent company of the Catalina Group of companies. Catalina Group was founded in 2005 and has been a successful consolidator of businesses and portfolios within the non-life and reinsurance sector. This statement covers the activities of the Catalina Group and its approximately 350 staff, who are based in a number of jurisdictions, including: Bermuda, Ireland, Singapore, the United States and the UK. We have employees based in other locations who are also the subject of this statement.
Our policy on modern slavery and human trafficking
The Catalina Group is committed to preventing slavery and human trafficking occurring in any of its corporate activities. As a professional services group, our services are delivered to our policyholders, other Catalina Group companies and third parties. Our commitment is to ensure that those organisations with whom we contract to receive goods and services are aware of our policies in order to comply with this statement.
The Board of CHBL believes that our business model presents a low risk of exposure to slavery or human trafficking but we are not complacent and we wish to ensure that we meet legal and regulatory obligations wherever we operate and to uphold the rights of the individual and human dignity. We expect the same standards from all the parties with whom we contract and partner.
This commitment is evident through our company policies, which aim to uphold the highest ethical and professional standards.
Policies relating to slavery and human trafficking
The Catalina “Flight Plan” sets out our core values, including the requirement that we adhere to the highest standards, choosing the right way over the easy way.
The following Catalina Group policies also support our commitment to working to influence and mitigate the risk of modern slavery in our organisation and supply chain, through ensuring that robust standards and processes are in place across our business to manage risks relating to our relationships with third parties:
- Anti-Bribery and Corruption Policy
- Anti-Money Laundering Policy
- Global ESG Policy
- Outsourcing Risk Management Framework
- Sanctions Policy
- Whistleblowing Policy
The Whistleblowing Policy encourages our employees to raise concerns about how we do business or operate as an employer without fear of retaliation. These Catalina Group policies are also supported and in the UK by the additional policies and procedures, including the UK Outsourcing Policy.
The policies are available to our workforce via our intranet sites and, where appropriate, colleagues complete annual training modules to ensure they understand their responsibilities.
We are an equal opportunities employer, committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. Our recruitment and people-management processes are designed to ensure that all prospective employees are legally entitled to work wherever they are based, and, we check references and make legal and regulatory enquiries (to the extent allowed by local law and practice) in order to safeguard employees and contractors from any abuse or coercion.
We make our people aware of our policies and of their employment rights in several ways, including through our intranet site, their written employment offers, and the company inductions. All colleagues are required to complete training on whistleblowing, which provides guidance on how to raise concerns in a secure and confidential way. If a colleague has any concerns that they want to bring to the attention of the business, including concerns about a breach of law such as slavery and human trafficking, they are trained to raise these in accordance with the Whistleblowing Policy.
Through our formal channels of reporting there were no cases of human rights issues raised in 2021.
The business of the Catalina Group is focused on the administration and handling of claims for run-off underwriting business, which is a regulated financial services activity. Accordingly, our supply chains are limited. We outsource some functions relating specifically to the support of claims activities to reputable professional firms, many of whom are regulated by a local insurance regulator.
We do not enter into business with any organisation wherever they are based, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour. As part of our process of selecting new suppliers and business partners we carry out due diligence that includes a risk assessment of their approach to ethical matters including policies and procedures to avoid modern slavery and human trafficking.
The Board of Directors of CHBL has approved this statement on behalf of the Catalina Group of companies and the actions contained herein.
This statement will be posted on the company intranet together with all other company policies and procedures. It is an annual agenda item for discussion and consultation with our Boards. It reflects our commitment to implementing and enforcing effective procedures and controls to minimise the risks of human trafficking and other modern slavery practices infiltrating our business operations and acting ethically and with integrity in all our business activities and relationships.
This statement will be reviewed and updated every year.